Table of Contents:
- Information We Collect and Receive
- How We Use Information
- Data Retention
- How We Share and Disclose Information
- Age Limitations
- International Data Transfers
- Data Protection Officer
- Identifying the Data Controller and Processor
- Your Rights
- California Privacy Rights
- Data Protection Authority
- Contacting upLVL
Information We Collect And Receive
upLVL may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to a Learning Environment by a Customer (“Authorized Users”) routinely submit Customer Data to upLVL when using the Services.
- Other Information. upLVL also collects, generates and/or receives Other Information:
- Learning Environment and account information. To create or update a Learning Environment account, you or your Customer (e.g. your employer) supply upLVL with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide upLVL (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
- Usage information.
- Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, upLVL logs the Learning Environments, channels, people, features, content and links you view or interact with, the types of files shared and what Third-Party Services are used (if any).
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device information. upLVL collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer or an IP address received from your browser or device to determine approximate location. upLVL may also collect location information from devices in accordance with the consent process provided by your device.
- Cookie information. upLVL uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information.
- Third-Party services. A Customer can choose to permit or restrict Third-Party Services for its Learning Environment. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Learning Environment. upLVL may also develop and offer upLVL applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with upLVL. For example, if a cloud storage application is enabled to permit files to be imported to a Learning Environment, we may receive the user name and email address of Authorized Users, along with additional information that the application has elected to make available to upLVL to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to upLVL. When a Third-Party Service is enabled, upLVL is authorized to connect and access Other Information made available to upLVL in accordance with our agreement with the Third-Party Provider and any permission(s) granted by Customer (including, by its Authorized User(s)). We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
- Contact information. In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as an address book from a device or API) is collected when using the Services.
- Third-Party data. upLVL may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional information provided to upLVL. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by upLVL or a vendor, request support, interact with our social media accounts or otherwise communicate with upLVL.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Learning Environment setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by upLVL in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. upLVL is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Learning Environment, assign roles and configure settings, access, share Customer Data.
upLVL uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, upLVL uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features. upLVL tries to make the Services as useful as possible for specific Learning Environments and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services or Third-Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about upLVL. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from upLVL please get in touch through the contact mechanisms described below.
- For billing, account management and other administrative matters. upLVL may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
How We Share And Disclose Information
This section describes how upLVL may share and disclose Information, as described in the section entitled ‘Information We Collect and Receive’ above. Customers determine their own policies and practices for the sharing and disclosure of Information. upLVL does not control how they or any other third parties choose to share or disclose Information.
- The Customer’s Instructions. upLVL may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
- Displaying the Services. When an Authorized User submits Information, it may be displayed to other Authorized Users in the same or connected Learning Environments. For example, an Authorized User’s email address may be displayed with their Learning Environment profile.
- Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using Service features to export logs of Learning Environment activity, or accessing or modifying your profile details.
- Third-Party Service Providers and Partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers.
- Forums. The information you choose to provide in a community forum including personal data will be publicly available.
- Corporate Affiliates. upLVL may share Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to upLVL’s Business. If upLVL engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of upLVL’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or deidentified Information for any purpose. For example, we may share aggregated or deidentified Information with prospects or partners for business or research
- To Comply with Laws. If we receive a request for information, we may disclose Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of upLVL, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
- With Consent. upLVL may share Information with third parties when we have consent to do so. For Learning Environments registered to corporate entities, upLVL may share Information with consent of the Learning Environment Primary Owner or authorized corporate officer. For workplaces created without a formal affiliation, upLVL may require user consent.
upLVL takes security of data very seriously. upLVL works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. upLVL has received internationally recognized security certifications. Given the nature of communications and information processing technology, upLVL cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site, and we don’t control or endorse what is on third-party sites.
To the extent prohibited by applicable law, upLVL does not allow use of our Services and Websites by anyone younger than 21 years old. If you learn that anyone younger than 21 has unlawfully provided us with personal data, please contact us, and we will take steps to delete such information.
International Data Transfers
upLVL may transfer your Personal Data to countries other than the one in which you live. To the extent that Personal Data is transferred abroad, upLVL will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with upLVL’s obligations.
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, upLVL is the processor of Customer Data and the controller of Other Information.
Individuals across the globe, including the European Economic Area, the United Kingdom and Brazil, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your Learning Environment for additional access and assistance.
Your California Privacy Rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@upLVL.net. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
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